alps distributors, inc

BrokerCheck Report

ALPS DISTRIBUTORS, INC.

Section Title

Report Summary

Firm History

CRD# 16853

1

7

Firm Profile 2 - 6

Page(s)

Firm Operations 8 - 17

Disclosure Events 18

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CRD# 16853

SEC# 8-34626

Main Office Location

1290 BROADWAY, SUITE 1000DENVER, CO 80203Regulated by FINRA Denver Office

Mailing Address

PO BOX 328DENVER, CO 80201-0328

Business Telephone Number

303-623-2577

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 4

Firm Profile

This firm is classified as a corporation.

This firm was formed in Colorado on 07/01/1985.

Its fiscal year ends in December.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 3 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm does not have referral or financialarrangements with other brokers or dealers.

This firm is registered with:

• the SEC• 1 Self-Regulatory Organization• 53 U.S. states and territories

www.finra.org/brokercheck User Guidance

1©2021 FINRA. All rights reserved. Report about ALPS DISTRIBUTORS, INC.


http://www.finra.org/brokercheck

http://www.finra.org/brokercheck_reports


This firm is classified as a corporation.

This firm was formed in Colorado on 07/01/1985.

CRD#

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.

Firm Profile

Firm Names and Locations

Its fiscal year ends in December.


SEC#

16853

8-34626

Main Office Location

Mailing Address

Business Telephone Number

Doing business as ALPS DISTRIBUTORS, INC.

303-623-2577

Regulated by FINRA Denver Office

1290 BROADWAY, SUITE 1000DENVER, CO 80203

PO BOX 328DENVER, CO 80201-0328






This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

ALPS HOLDINGS, INC.

PARENT

75% or more

No

Domestic Entity

09/2005

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


KYLLO, STEPHEN JOHN

SVP; PRESIDENT; DIRECTOR; CHIEF COMPLIANCE OFFICER; PRINCIPALOPERATIONS OFFICER

Less than 5%

No

Individual

04/2020

Yes

3204474



Position

Position Start Date

PARSONS, ERIC T

FINOP, PRINCIPAL FINANCIAL OFFICER

Individual

06/2021

5215115








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

No






This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

DST SYSTEMS, INC.

OWNER

ALPS HOLDINGS, INC.

75% or more

Yes

Domestic Entity

11/2011

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established




SS&C TECHNOLOGIES HOLDINGS, INC.

OWNER

SS&C TECHNOLOGIES, INC.

75% or more

Yes

Domestic Entity

11/2005

Yes









SS&C TECHNOLOGIES, INC.

DST SYSTEMS, INC.

Domestic Entity









Indirect Owners (continued)

Firm Profile

OWNER

DST SYSTEMS, INC.

75% or more

No

04/2018

Yes












Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.






Firm Operations

RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.

This firm is currently registered with the SEC, 1 SRO and 53 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

No

No

No

Federal Regulator Status Date Effective

SEC Approved 09/25/1985

Self-Regulatory Organization Status Date Effective

FINRA Approved 12/02/1985






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 10/04/1989

Alaska Approved 04/28/1989

Arizona Approved 05/18/1988

Arkansas Approved 09/14/1993

California Approved 04/21/1988

Colorado Approved 12/09/1985

Connecticut Limited 06/08/1989

Delaware Approved 06/06/1989

District of Columbia Approved 04/17/1993

Florida Approved 03/07/1988

Georgia Approved 04/14/1989

Hawaii Approved 04/05/1993

Idaho Approved 07/19/1988

Illinois Approved 01/15/1988

Indiana Approved 04/22/1988

Iowa Approved 04/07/1988

Kansas Approved 03/08/1989

Kentucky Approved 04/04/1989

Louisiana Approved 05/16/1994

Maine Approved 06/15/1993

Maryland Approved 04/30/1990

Massachusetts Approved 05/31/1989

Michigan Approved 03/30/1988

Minnesota Approved 02/24/1988

Mississippi Approved 06/07/1989

Missouri Approved 02/05/1993

Montana Approved 06/29/1988

Nebraska Limited 05/22/1989

Nevada Limited 11/03/1988

New Hampshire Limited 04/18/1989

New Jersey Approved 03/25/1993

New Mexico Approved 01/06/1989

New York Approved 03/16/1989

U.S. States &Territories

Status Date Effective

North Carolina Approved 04/04/1989

North Dakota Limited 05/22/1989

Ohio Approved 04/01/1988

Oklahoma Approved 09/29/1988

Oregon Approved 02/18/1987

Pennsylvania Approved 05/11/1989

Puerto Rico Approved 07/19/1995

Rhode Island Approved 04/06/1993

South Carolina Approved 04/18/1989

South Dakota Approved 04/11/1989

Tennessee Approved 03/02/1989

Texas Limited 07/13/1988

Utah Approved 08/11/1988

Vermont Approved 05/13/1993

Virgin Islands Approved 08/22/2005

Virginia Approved 02/04/1993

Washington Limited 04/15/1988

West Virginia Approved 03/19/1993

Wisconsin Approved 01/08/1988

Wyoming Approved 10/13/1988






Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

Other Types of Business

This firm does not effect transactions in commodities, commodity futures, or commodity options.This firm does not engage in other non-securities business.

Non-Securities Business Description:

This firm currently conducts 3 types of businesses.

Types of Business

Mutual fund underwriter or sponsor

Private placements of securities

Other - ACT AS WHOLESALER AND/OR MARKETING AGENT FOR EXCHANGE-TRADED SECURITIESREGISTERED UNDER THE SECURITIES ACT'S OF 1933, 1934, 1940 AND THE PHILANTHROPY PROTECTIONACT.






Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does not refer or introduce customers to other brokers and dealers.






Firm Operations

Industry Arrangements

This firm does have books or records maintained by a third party.

Name: QUEST CE

Business Address: 10850 WEST PARK PLACESUITE 1000MILWAUKEE, WI 53224

Effective Date: 01/01/2015

Description: QUEST CE'S ONLINE SOFTWARE IS USED TO MANAGE AND RETAINSTHE FIRMS RECORDS IN RELATION TO REGISTRATION AND LICENSING,AML TRAINING, FIRM ELEMENT, AND ANNUAL COMPLIANCEINTERVIEWS.

Name: SCHWAB COMPLIANCE TECHNOLOGIES, INC.

Business Address: 125 S. WACKER DRIVESUITE 1150CHICAGO, IL 60606


Description: SCHWAB COMPLIANCE TECHNOLOGIES, INC. IS A REGULATORYCOMPLIANCE SOFTWARE PRODUCT THAT OFFERS SOFTWARE TOMAINTAIN AND TRACK PERSONAL TRADING ACCOUNTS OF ACCESSPERSONS TO COMPLY WITH THE FIRMS CODE OF ETHICS POLICY.

Name: IRON MOUNTAIN

Business Address: 5050 MOLINE STREETDENVER, CO 80239


Description: IRON MOUNTAIN OFFERS OFF-SITE STORAGE OF BROKER-DEALERRECORDS AT THEIR SECURE FACILITY.

Name: GLOBAL RELAY COMMUNICATIONS INC.

Business Address: 410 PARK AVENUE15TH FLOORNEW YORK, NY 10022


Description: GLOBAL RELAY COMMUNICATIONS, INC. WILL SERVE AS ADI'SCOMPLIANCE MESSAGE ARCHIVING AND MONITORING SERVICEPROVIDER. GLOBAL RELAY WILL IMPLEMENT ELECTRONIC STORAGEMEDIA TO STORE CERTAIN BOOKS AND RECORDS AS REQUIRED BYSEC RULE 17A-3 AND/OR 17A-4. 12©2021 FINRA. All rights reserved. Report about ALPS DISTRIBUTORS, INC.





Firm Operations

Industry Arrangements (continued)

This firm does not have accounts, funds, or securities maintained by a third party.

This firm does not have customer accounts, funds, or securities maintained by a third party.

This firm does not have individuals who control its management or policies through agreement.

This firm does not have individuals who wholly or partly finance the firm's business.

Control Persons/Financing

GLOBAL RELAY COMMUNICATIONS, INC. WILL SERVE AS ADI'SCOMPLIANCE MESSAGE ARCHIVING AND MONITORING SERVICEPROVIDER. GLOBAL RELAY WILL IMPLEMENT ELECTRONIC STORAGEMEDIA TO STORE CERTAIN BOOKS AND RECORDS AS REQUIRED BYSEC RULE 17A-3 AND/OR 17A-4.






Firm Operations

Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.

This firm is, directly or indirectly:

· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.

No

Yes

AUSTRALIA

Yes

10/01/2018

LEVEL 179 CASTLEREAGH STREETSYDNEY, AUSTRALIA NSW 2000

EZE SOFTWARE GROUP PTY LIMITED is under common control with the firm.

EZE SOFTWARE GROUP PTY LIMITED IS UNDER COMMON CONTROL OFTHE FIRMS INDIRECT OWNER, SS&C TECHNOLOGIES HOLDINGS, INC.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

10/01/2018

12 FARNSWORTH STREET6TH FLOORBOSTON, MA 02210

132246

EZE CASTLE TRANSACTION SERVICES LLC is under common control with the firm.

EZE CASTLE TRANSACTION SERVICES LLC IS UNDER COMMON CONTROLOF THE FIRMS INDIRECT OWNER, SS&C TECHNOLOGIES HOLDINGS, INC.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations

Organization Affiliates (continued)

No

Yes

No

04/01/2018

21860 BURBANK BLVDSUITE 150WOODLAND HILLS, CA 91367

42404

SECOND STREET SECURITIES, INC. is under common control with the firm.

SECOND STREET SECURITIES, INC. IS UNDER COMMON CONTROL OF THEFIRMS INDIRECT OWNER, SS&C TECHNOLOGIES.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

No

07/31/2015

25188 GENESEE TRAIL ROADSUITE 250GOLDEN, CO 80401

135117

RED ROCKS CAPITAL LLC is under common control with the firm.

RED ROCKS CAPITAL, LLC IS UNDER COMMON CONTROL THROUGH ALPSADVISORS, INC AND DST SYSTEMS, INC.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

10/31/2011

920 2ND AVENUE SOUTHSUITE 700MINNEAPOLIS, MN 55402

23568

SS&C MARKET SERVICES, LLC is under common control with the firm.

Effective Date:

Business Address:

CRD #:






Firm Operations


No

Yes

No

10/31/2011

SS&C MARKET SERVICES, LLC IS UNDER COMMON CONTROL OF THEFIRMS INDIRECT OWNER, SS&C TECHNOLOGIES.

Description:



Country:

Foreign Entity:

Effective Date:

No

Yes

No

03/19/2007


144464

ALPS PORTFOLIO SOLUTIONS DISTRIBUTOR, INC. is under common control with the firm.

ALPS PORTFOLIO SOLUTIONS DISTRIBUTOR, INC. IS A SUBSIDIARY OFALPS HOLDINGS, INC. ALPS HOLDINGS INC. IS ALSO THE PARENTCOMPANY TO ALPS DISTRIBUTORS, INC.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

No

12/18/2006


134340

ALPS ADVISORS, INC. is under common control with the firm.



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


ALPS ADVISORS, INC. IS A SUBSIDIARY OF ALPS HOLDINGS, INC. ALPSHOLDINGS INC. IS ALSO THE PARENT COMPANY TO ALPS DISTRIBUTORS,INC.

Description:

This firm is not directly or indirectly, controlled by the following:

· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank






Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 4 0






Disclosure Event Details

What you should know about reported disclosure events:

1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includessummary information regarding FINRA arbitration awards in cases where the brokerage firm wasnamed as a respondent.

2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a

particular criminal event.3. Disclosure events in BrokerCheck reports come from different sources:

o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.

4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final.

§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently

being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,

or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

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§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.

5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.

Regulatory - Final

This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.

Disclosure 1 of 4

Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN ITS ROLEAS DISTRIBUTOR FOR FIVE EXCHANGE TRADED PRODUCTS (ETPS)REGISTERED UNDER THE INVESTMENT COMPANY ACT OF 1940, THE FIRMAPPROVED FIVE CREATION REQUESTS THAT DID NOT COMPLY WITH THEREQUIREMENTS FOR MANUAL ORDERS SET FORTH IN THE RELEVANTGOVERNING DOCUMENTS. THE FINDINGS STATED THAT ALTHOUGH THEAUTHORIZED PARTICIPANTS (APS) PLACING THE ORDERS PROPERLYINITIATED THE ORDER PROCESS BY TELEPHONE PRIOR TO THERELEVANT ORDER CUTOFF TIMES, THE APS DID NOT SUBMIT THEIRCOMPLETED ORDER FORMS TO THE TRANSFER AGENT VIA FACSIMILEWITHIN THE REQUIRED TIMEFRAMES. THE FIRM NONETHELESSIMPROPERLY APPROVED THESE ORDERS FOR PROCESSING, INSTEAD OFTREATING THEM AS INVALID AS WAS REQUIRED BY THE RELEVANTGOVERNING DOCUMENTS. IN ITS ROLE AS MARKETING AGENT FOR THREEETPS REGISTERED UNDER THE SECURITIES ACT OF 1933, THE FIRMAPPROVED ONE CREATION REQUEST AND TWO REDEMPTION REQUESTSTHAT DID NOT COMPLY WITH THE REQUIREMENTS FOR MANUAL ORDERSSET FORTH IN THE RELEVANT GOVERNING DOCUMENTS. THE FIRMNONETHELESS IMPROPERLY APPROVED THESE ORDERS FORPROCESSING, INSTEAD OF TREATING THEM AS INVALID AS REQUIRED BYTHE RELEVANT GOVERNING DOCUMENTS. IN ITS ROLE AS MARKETINGAGENT FOR AN ETP REGISTERED UNDER THE SECURITIES ACT OF 1933,THE FIRM APPROVED A MANUAL REDEMPTION ORDER THAT DID NOTCOMPLY WITH THE REQUIREMENTS SET FORTH IN THE RELEVANTGOVERNING DOCUMENTS. AFTER RECEIVING THE ORDER FORM NINEMINUTES LATER, THE FIRM NONETHELESS IMPROPERLY APPROVED THISORDER, INSTEAD OF TREATING THE ORDER AS INVALID AS REQUIRED BYTHE RELEVANT GOVERNING DOCUMENTS. THE FINDINGS ALSO STATEDTHAT FOR 219 ADDITIONAL MANUAL ORDERS FOR CREATIONS ORREDEMPTIONS THAT WERE PROCESSED BY THE FIRM, THE FIRM FAILEDTO MAKE AND PRESERVE ACCURATE BOOKS AND RECORDS OF SUCHORDERS AS THE ORDERS CONTAINED MISSING, UNINTELLIGIBLE ORERRONEOUS INFORMATION, INCLUDING MISSING OR INACCURATEFACSIMILE TIME STAMPS OR TIME STAMPS THAT WERE PRIOR TO ORAFTER THE TIMES THE ORDERS WERE ACTUALLY PLACED. DUE TO THESEERRORS, FINRA WAS UNABLE TO DETERMINE WHETHER ADDITIONALORDERS FOR THE CREATION OR REDEMPTION OF ETPS SHARES WEREPROCESSED WITHIN THE REQUIRED TIMEFRAMES. THE FINDINGS ALSOINCLUDED THAT THE FIRM'S SUPERVISORY SYSTEM, INCLUDING ITSWRITTEN SUPERVISORY PROCEDURES (WSPS), DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE RULES AND REGULATIONS CONCERNING THE CREATION ORREDEMPTION APPROVAL PROCESS FOR ETPS. IN PARTICULAR, THE FIRMDID NOT HAVE ADEQUATE PROCEDURES TO ENSURE THAT ORDERS FORTHE CREATION AND REDEMPTION OF ETPS ADHERED TO THE RELEVANTCUTOFF TIMES AND THAT SUCH ORDERS WERE COMPLETED WITHIN THEREQUIRED TIMEFRAMES SET FORTH IN THE RELEVANT GOVERNINGDOCUMENTS, BEFORE THEY WERE APPROVED. THE FIRM FAILED TO HAVEIN PLACE AN ADEQUATE SUPERVISORY PROCESS AND REVIEW FORCOMPARISONS BETWEEN ELECTRONIC FAX SERVER RECORDS AND THEHANDWRITTEN ORDER DOCUMENTS MAINTAINED BY ITS TRADEPROCESSING DEPARTMENT, AS WELL AS FOR REVIEW OF ANY MATERIALINCONSISTENCIES IN RECORDS OR ANY INSTANCES IN WHICH FAXORDERS WERE RECEIVED OUTSIDE OF THE STATED CUTOFF TIMES ORTIMEFRAMES OUTLINED IN THE GOVERNING DOCUMENTS. MOREOVER,THE FIRM'S WSPS REFERENCED CHECKLISTS THAT FIRM EMPLOYEESWERE REQUIRED TO COMPLETE FOR THE AUTHORIZATION OF CREATIONOR REDEMPTION REQUESTS. THE FIRM'S WSPS FAILED TO REFERENCEANY SUPERVISORY REVIEW OF THE CREATION OR REDEMPTION ORDERTAKING AND APPROVAL PROCESS FOR ETPS, AND THE FIRM DID NOTPRODUCE ADEQUATE EVIDENCE OF SUCH SUPERVISORY REVIEWS.

Current Status: Final






Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN ITS ROLEAS DISTRIBUTOR FOR FIVE EXCHANGE TRADED PRODUCTS (ETPS)REGISTERED UNDER THE INVESTMENT COMPANY ACT OF 1940, THE FIRMAPPROVED FIVE CREATION REQUESTS THAT DID NOT COMPLY WITH THEREQUIREMENTS FOR MANUAL ORDERS SET FORTH IN THE RELEVANTGOVERNING DOCUMENTS. THE FINDINGS STATED THAT ALTHOUGH THEAUTHORIZED PARTICIPANTS (APS) PLACING THE ORDERS PROPERLYINITIATED THE ORDER PROCESS BY TELEPHONE PRIOR TO THERELEVANT ORDER CUTOFF TIMES, THE APS DID NOT SUBMIT THEIRCOMPLETED ORDER FORMS TO THE TRANSFER AGENT VIA FACSIMILEWITHIN THE REQUIRED TIMEFRAMES. THE FIRM NONETHELESSIMPROPERLY APPROVED THESE ORDERS FOR PROCESSING, INSTEAD OFTREATING THEM AS INVALID AS WAS REQUIRED BY THE RELEVANTGOVERNING DOCUMENTS. IN ITS ROLE AS MARKETING AGENT FOR THREEETPS REGISTERED UNDER THE SECURITIES ACT OF 1933, THE FIRMAPPROVED ONE CREATION REQUEST AND TWO REDEMPTION REQUESTSTHAT DID NOT COMPLY WITH THE REQUIREMENTS FOR MANUAL ORDERSSET FORTH IN THE RELEVANT GOVERNING DOCUMENTS. THE FIRMNONETHELESS IMPROPERLY APPROVED THESE ORDERS FORPROCESSING, INSTEAD OF TREATING THEM AS INVALID AS REQUIRED BYTHE RELEVANT GOVERNING DOCUMENTS. IN ITS ROLE AS MARKETINGAGENT FOR AN ETP REGISTERED UNDER THE SECURITIES ACT OF 1933,THE FIRM APPROVED A MANUAL REDEMPTION ORDER THAT DID NOTCOMPLY WITH THE REQUIREMENTS SET FORTH IN THE RELEVANTGOVERNING DOCUMENTS. AFTER RECEIVING THE ORDER FORM NINEMINUTES LATER, THE FIRM NONETHELESS IMPROPERLY APPROVED THISORDER, INSTEAD OF TREATING THE ORDER AS INVALID AS REQUIRED BYTHE RELEVANT GOVERNING DOCUMENTS. THE FINDINGS ALSO STATEDTHAT FOR 219 ADDITIONAL MANUAL ORDERS FOR CREATIONS ORREDEMPTIONS THAT WERE PROCESSED BY THE FIRM, THE FIRM FAILEDTO MAKE AND PRESERVE ACCURATE BOOKS AND RECORDS OF SUCHORDERS AS THE ORDERS CONTAINED MISSING, UNINTELLIGIBLE ORERRONEOUS INFORMATION, INCLUDING MISSING OR INACCURATEFACSIMILE TIME STAMPS OR TIME STAMPS THAT WERE PRIOR TO ORAFTER THE TIMES THE ORDERS WERE ACTUALLY PLACED. DUE TO THESEERRORS, FINRA WAS UNABLE TO DETERMINE WHETHER ADDITIONALORDERS FOR THE CREATION OR REDEMPTION OF ETPS SHARES WEREPROCESSED WITHIN THE REQUIRED TIMEFRAMES. THE FINDINGS ALSOINCLUDED THAT THE FIRM'S SUPERVISORY SYSTEM, INCLUDING ITSWRITTEN SUPERVISORY PROCEDURES (WSPS), DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE RULES AND REGULATIONS CONCERNING THE CREATION ORREDEMPTION APPROVAL PROCESS FOR ETPS. IN PARTICULAR, THE FIRMDID NOT HAVE ADEQUATE PROCEDURES TO ENSURE THAT ORDERS FORTHE CREATION AND REDEMPTION OF ETPS ADHERED TO THE RELEVANTCUTOFF TIMES AND THAT SUCH ORDERS WERE COMPLETED WITHIN THEREQUIRED TIMEFRAMES SET FORTH IN THE RELEVANT GOVERNINGDOCUMENTS, BEFORE THEY WERE APPROVED. THE FIRM FAILED TO HAVEIN PLACE AN ADEQUATE SUPERVISORY PROCESS AND REVIEW FORCOMPARISONS BETWEEN ELECTRONIC FAX SERVER RECORDS AND THEHANDWRITTEN ORDER DOCUMENTS MAINTAINED BY ITS TRADEPROCESSING DEPARTMENT, AS WELL AS FOR REVIEW OF ANY MATERIALINCONSISTENCIES IN RECORDS OR ANY INSTANCES IN WHICH FAXORDERS WERE RECEIVED OUTSIDE OF THE STATED CUTOFF TIMES ORTIMEFRAMES OUTLINED IN THE GOVERNING DOCUMENTS. MOREOVER,THE FIRM'S WSPS REFERENCED CHECKLISTS THAT FIRM EMPLOYEESWERE REQUIRED TO COMPLETE FOR THE AUTHORIZATION OF CREATIONOR REDEMPTION REQUESTS. THE FIRM'S WSPS FAILED TO REFERENCEANY SUPERVISORY REVIEW OF THE CREATION OR REDEMPTION ORDERTAKING AND APPROVAL PROCESS FOR ETPS, AND THE FIRM DID NOTPRODUCE ADEQUATE EVIDENCE OF SUCH SUPERVISORY REVIEWS.






Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 10/14/2015

Docket/Case Number: 2011029728201

Principal Product Type: Other

Other Product Type(s): EXCHANGE TRADED PRODUCTS

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN ITS ROLEAS DISTRIBUTOR FOR FIVE EXCHANGE TRADED PRODUCTS (ETPS)REGISTERED UNDER THE INVESTMENT COMPANY ACT OF 1940, THE FIRMAPPROVED FIVE CREATION REQUESTS THAT DID NOT COMPLY WITH THEREQUIREMENTS FOR MANUAL ORDERS SET FORTH IN THE RELEVANTGOVERNING DOCUMENTS. THE FINDINGS STATED THAT ALTHOUGH THEAUTHORIZED PARTICIPANTS (APS) PLACING THE ORDERS PROPERLYINITIATED THE ORDER PROCESS BY TELEPHONE PRIOR TO THERELEVANT ORDER CUTOFF TIMES, THE APS DID NOT SUBMIT THEIRCOMPLETED ORDER FORMS TO THE TRANSFER AGENT VIA FACSIMILEWITHIN THE REQUIRED TIMEFRAMES. THE FIRM NONETHELESSIMPROPERLY APPROVED THESE ORDERS FOR PROCESSING, INSTEAD OFTREATING THEM AS INVALID AS WAS REQUIRED BY THE RELEVANTGOVERNING DOCUMENTS. IN ITS ROLE AS MARKETING AGENT FOR THREEETPS REGISTERED UNDER THE SECURITIES ACT OF 1933, THE FIRMAPPROVED ONE CREATION REQUEST AND TWO REDEMPTION REQUESTSTHAT DID NOT COMPLY WITH THE REQUIREMENTS FOR MANUAL ORDERSSET FORTH IN THE RELEVANT GOVERNING DOCUMENTS. THE FIRMNONETHELESS IMPROPERLY APPROVED THESE ORDERS FORPROCESSING, INSTEAD OF TREATING THEM AS INVALID AS REQUIRED BYTHE RELEVANT GOVERNING DOCUMENTS. IN ITS ROLE AS MARKETINGAGENT FOR AN ETP REGISTERED UNDER THE SECURITIES ACT OF 1933,THE FIRM APPROVED A MANUAL REDEMPTION ORDER THAT DID NOTCOMPLY WITH THE REQUIREMENTS SET FORTH IN THE RELEVANTGOVERNING DOCUMENTS. AFTER RECEIVING THE ORDER FORM NINEMINUTES LATER, THE FIRM NONETHELESS IMPROPERLY APPROVED THISORDER, INSTEAD OF TREATING THE ORDER AS INVALID AS REQUIRED BYTHE RELEVANT GOVERNING DOCUMENTS. THE FINDINGS ALSO STATEDTHAT FOR 219 ADDITIONAL MANUAL ORDERS FOR CREATIONS ORREDEMPTIONS THAT WERE PROCESSED BY THE FIRM, THE FIRM FAILEDTO MAKE AND PRESERVE ACCURATE BOOKS AND RECORDS OF SUCHORDERS AS THE ORDERS CONTAINED MISSING, UNINTELLIGIBLE ORERRONEOUS INFORMATION, INCLUDING MISSING OR INACCURATEFACSIMILE TIME STAMPS OR TIME STAMPS THAT WERE PRIOR TO ORAFTER THE TIMES THE ORDERS WERE ACTUALLY PLACED. DUE TO THESEERRORS, FINRA WAS UNABLE TO DETERMINE WHETHER ADDITIONALORDERS FOR THE CREATION OR REDEMPTION OF ETPS SHARES WEREPROCESSED WITHIN THE REQUIRED TIMEFRAMES. THE FINDINGS ALSOINCLUDED THAT THE FIRM'S SUPERVISORY SYSTEM, INCLUDING ITSWRITTEN SUPERVISORY PROCEDURES (WSPS), DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE RULES AND REGULATIONS CONCERNING THE CREATION ORREDEMPTION APPROVAL PROCESS FOR ETPS. IN PARTICULAR, THE FIRMDID NOT HAVE ADEQUATE PROCEDURES TO ENSURE THAT ORDERS FORTHE CREATION AND REDEMPTION OF ETPS ADHERED TO THE RELEVANTCUTOFF TIMES AND THAT SUCH ORDERS WERE COMPLETED WITHIN THEREQUIRED TIMEFRAMES SET FORTH IN THE RELEVANT GOVERNINGDOCUMENTS, BEFORE THEY WERE APPROVED. THE FIRM FAILED TO HAVEIN PLACE AN ADEQUATE SUPERVISORY PROCESS AND REVIEW FORCOMPARISONS BETWEEN ELECTRONIC FAX SERVER RECORDS AND THEHANDWRITTEN ORDER DOCUMENTS MAINTAINED BY ITS TRADEPROCESSING DEPARTMENT, AS WELL AS FOR REVIEW OF ANY MATERIALINCONSISTENCIES IN RECORDS OR ANY INSTANCES IN WHICH FAXORDERS WERE RECEIVED OUTSIDE OF THE STATED CUTOFF TIMES ORTIMEFRAMES OUTLINED IN THE GOVERNING DOCUMENTS. MOREOVER,THE FIRM'S WSPS REFERENCED CHECKLISTS THAT FIRM EMPLOYEESWERE REQUIRED TO COMPLETE FOR THE AUTHORIZATION OF CREATIONOR REDEMPTION REQUESTS. THE FIRM'S WSPS FAILED TO REFERENCEANY SUPERVISORY REVIEW OF THE CREATION OR REDEMPTION ORDERTAKING AND APPROVAL PROCESS FOR ETPS, AND THE FIRM DID NOTPRODUCE ADEQUATE EVIDENCE OF SUCH SUPERVISORY REVIEWS.

Resolution Date: 10/14/2015

Resolution:

Other Sanctions Ordered: UNDERTAKING: ADDRESS THE DEFICIENCIES DESCRIBED ABOVE TOENSURE THAT THE FIRM HAS IMPLEMENTED PROCEDURES THAT AREREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THEAPPLICABLE RULES AND REGULATIONS.

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Sanctions Ordered: CensureMonetary/Fine $125,000.00

Acceptance, Waiver & Consent(AWC)





https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2011029728201


UNDERTAKING: ADDRESS THE DEFICIENCIES DESCRIBED ABOVE TOENSURE THAT THE FIRM HAS IMPLEMENTED PROCEDURES THAT AREREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THEAPPLICABLE RULES AND REGULATIONS.

Sanction Details: THE FIRM WAS CENSURED, FINED $125,000 AND UNDERTAKES TOADDRESS THE DEFICIENCIES DESCRIBED ABOVE TO ENSURE THAT THEFIRM HAS IMPLEMENTED PROCEDURES THAT ARE REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE RULES ANDREGULATIONS. FINE PAID IN FULL OCTOBER 27, 2015.

iReporting Source: Firm

Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA")


Civil and Administrative Penalt(ies) /Fine(s)


CENSURE AND AN UNDERTAKING REQUIRING ALPS DISTRIBUTORS, INC.TO SUBMIT A LETTER TO FINRA REPRESENTING THAT THE FIRM HASADDRESSED THE DEFICIENCIES SET FORTH IN THE LETTER OFACCEPTANCE, WAIVER AND CONSENT.


Docket/Case Number: 20110297282-01

Principal Product Type: Other

Other Product Type(s): EXCHANGE-TRADED PRODUCT

Allegations: FINRA FOUND THAT ALPS DISTRIBUTORS, INC. ("ADI") APPROVED CERTAINMANUAL ETP ORDERS THAT DID NOT COMPLY WITH THE REQUIREMENTSFOR MANUAL ORDERS OUTLINED IN RELEVANT DOCUMENTS; ADI FAILEDTO MAKE AND PRESERVE ACCURATE BOOKS AND RECORDS REGARDINGCERTAIN MANUAL ETP ORDERS; AND ADI DID NOT HAVE ADEQUATESUPERVISORY PROCEDURES TO ENSURE THAT MANUAL ORDERS FORTHE CREATION AND REDEMPTION OF ETPS ADHERED TO AND WERECOMPLETED WITHIN THE REQUIRED TIMEFRAMES SET FORTH IN THERELEVANT DOCUMENTS.



Resolution:

Other Sanctions Ordered: UNDERTAKING REQUIRING ALPS DISTRIBUTORS, INC. TO SUBMIT ALETTER TO FINRA REPRESENTING THAT THE FIRM HAS ADDRESSED THEDEFICIENCIES SET FORTH IN THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT.








UNDERTAKING REQUIRING ALPS DISTRIBUTORS, INC. TO SUBMIT ALETTER TO FINRA REPRESENTING THAT THE FIRM HAS ADDRESSED THEDEFICIENCIES SET FORTH IN THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT.

Sanction Details: ALPS DISTRIBUTORS, INC. PAID A FINE OF $125,000 ON OCTOBER 27, 2015.NO PORTION OF THE PENALTY WAS WAIVED.

Firm Statement ON OCTOBER 14, 2015, FINRA ISSUED A NOTICE OF ACCEPTANCE OF ALETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") IN CONNECTIONWITH ITS REVIEW OF ADI'S ROLE IN THE CREATION AND REDEMPTION OFCERTAIN EXCHANGE TRADED PRODUCTS ("ETPS") DURING A 60 DAYPERIOD IN 2011. ADI CONSENTED TO THE ENTRY OF THE AWC WITHOUTADMITTING OR DENYING THE FINDINGS. AS SET FORTH IN THE AWC,FINRA FOUND THAT: ADI APPROVED CERTAIN MANUAL ETP ORDERS THATDID NOT COMPLY WITH THE REQUIREMENTS FOR MANUAL ORDERSOUTLINED IN RELEVANT DOCUMENTS; ADI FAILED TO MAKE ANDPRESERVE ACCURATE BOOKS AND RECORDS REGARDING CERTAINMANUAL ETP ORDERS; AND ADI DID NOT HAVE ADEQUATE SUPERVISORYPROCEDURES TO ENSURE THAT MANUAL ORDERS FOR THE CREATIONAND REDEMPTION OF ETPS ADHERED TO AND WERE COMPLETED WITHINTHE REQUIRED TIMEFRAMES SET FORTH IN THE RELEVANT DOCUMENTS.IN CONNECTION WITH THE SETTLEMENT, ADI AGREED TO A CENSURE, AFINE OF $125,000 AND AN UNDERTAKING REQUIRING ADI TO SUBMIT ALETTER TO FINRA REPRESENTING THAT THE FIRM HAS ADDRESSED THEDEFICIENCIES SET FORTH IN THE AWC.

Disclosure 2 of 4

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.




Docket/Case Number: C3A980014

Principal Product Type:

Other Product Type(s):

Allegations:



Resolution: Acceptance, Waiver & Consent(AWC)







Other Sanctions Ordered:

Sanction Details:

Regulator Statement ON APRIL 16, 1998, DISTRICT NO. 3 NOTIFIED RESPONDENTS ALPSMUTUAL FUNDS SERVICES AND THOMAS A. CARTER THAT THE LETTER OFACCEPTANCE, WAIVER AND CONSENT NO. C3A980014 WAS ACCEPTED;THEREFORE, THEY ARE CENSURED AND FINED $5,000, JOINTLY ANDSEVERALLY - (NASD RULE 2110 - RESPONDENT MEMBER, ACTINGTHROUGHRESPONDENT CARTER, CONDUCTED A SECURITIES BUSINESS WHILEFAILING TO MAINTAIN THE MINIMUM NET CAPITAL REQUIRED BY SECRULE 15c3-1).

**$5,000.00 PAID J&S ON 5/14/98, INVOICE #98-3A-388**



Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.


Censure


NONE


Docket/Case Number: C3A980014

Principal Product Type: Mutual Fund(s)


Allegations: IT WAS ALLEGED ON JULY 31, AUG. 29, SEPT. 30, AND NOV. 30,1997,APPLICANT, ACTING THROUGH MR. CARTER, CONDUCTEDSECURITIES BUSINESS WHILE FAILING TO MAINTAIN MINIMUM NETCAPITAL REQUIREMENTS UNDER SEC RULE 15C3-1 AND NASD RULE 2110.



Resolution:










Sanction Details: ALPS AGREED TO THE FOLLOWING ACTIONS: 1) CFO WILL OBTAIN THESERIES 28 FINOP LICENSE; 2) A NEW ATTORNEY HAS BEEN HIRED TOASSIST WITH BD COMPLIANCE; 3) A NEW CPA HAS BEEN HIRED ASCONTROLLER; 4) NEW NET CAPITAL REVIEW PROCEDURE IS IN PLACE; 5)ALPS PRINCIPALS RE-EDUCATED ON CAPITAL IMPLICATIONS OFTRANSACTIONS AND HAVE COMMITTED TO CAPITAL INJECTIONS IFNECESSARY.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, ALPS SUBMITTEDTO THE NASD AN AWC FOR THE ALLEGED VIOLATIONS. ALPS AGREED TO ACENSURE, A $5,000 FINE AND TO TAKE CORRECTIVE ACTION DETAILEDABOVE.

Disclosure 3 of 4

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Initiated By: MT SECURITIES DEPT.




Docket/Case Number: 4-7-92-8

URL for Regulatory Action:



Allegations: VIOLATIONS OF SECURITIES REGISTRATIONPROVISIONS OF MT SECURITIES ACT.



Resolution:


Sanction Details: CONSENT AGREEMENT ENTERED. WITHOUT ADMITTING ORDENYING ALLEGATIONS, RESPONDENTS AGREED TO ABIDE BY THE MTSECURITES ACT IN THE FUTURE, OFFER RESCISSION TO MT INVESTORS,AND PAY FINE OF $5,000.00

Sanctions Ordered: Monetary/Fine $5,000.00

Consent






CONSENT AGREEMENT ENTERED. WITHOUT ADMITTING ORDENYING ALLEGATIONS, RESPONDENTS AGREED TO ABIDE BY THE MTSECURITES ACT IN THE FUTURE, OFFER RESCISSION TO MT INVESTORS,AND PAY FINE OF $5,000.00

Regulator Statement Not Provided


Initiated By: MONTANA STATE AUDITOR


Civil and Administrative Penalt(ies) /Fine(s)


CONSENT AGREEMENT WAS SIGNED BY ALL PARTIES. ALPS PAID ANADMINISTRATIVE FINE OF $5,000 AND AN OFFER OF RESCISSIONWASMADE TO ALL AFFECTED SHAREHOLDERS IN ACCORDANCE WITH STATEPROCEDURES.


Docket/Case Number: UNKNOWN



Allegations: AS ADMINISTRATOR OF THE WESTCORE TRUST MUTUAL FUNDS,APPLICANT WAS REPONSIBLE FOR ALL BLUE SKY RENEWALS. SHARES OFAN UNREGISTERED MUTUAL FUND WERE INADVERTENTLY SOLD DUE TO AFAILURE TO RENEW IN MONTANA ON A TIMELY BASIS. THE FAILURE TORENEW WAS THE RESULT OF AN INADVERTENT CLERICAL OVERSIGHTAND WAS BROUGHT TO THE ATTENTION OF THE STATE OF MONTANAUPON DISCOVERY.



Resolution:

Other Sanctions Ordered: NONE.

Sanction Details: CONSENT AGREEMENT WAS SIGNED BY ALL PARTIES, ALPS PAID ANADMINISTRATIVE FINE OF $5,000 AND ALL AFFECTED SHAREHOLDERSWERE MADE WHOLE PLUS 10%. ALPS ALSO PAID WESTCORE'S LOSSES INCONNECTION WITH THE RESCISSION OFFER.

Sanctions Ordered: Monetary/Fine $5,000.00

Consent

Disclosure 4 of 4

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Initiated By: MARYLAND




Docket/Case Number: BD-90-0076

URL for Regulatory Action:



Allegations:



Resolution:


Sanction Details:

Regulator Statement 4/4/90-FORM U6 (8036-07890) DISCLOSES: CRD ROSTER REFLECTS NOAGENT REGISTERED AS OF JANUARY 2, 1990. ORDER TO SHOW CAUSEANDSUMMARY SUSPENSION ISSUED ON JANUARY 30, 1990, VIOLATION OFSECTION 11-412(a)(2) OF THE ACT. ALPS SECURITIES, INC. DID NOTREQUEST A HEARING. FINAL ORDER OF REVOCATION ISSUED MARCH 14,1990. DOCKET/CASE NUMBER NOT APPLICABLE, DATED MARCH 14, 1990.

^5/17/90, AMENDED FORM U-6 (JDS #8048-12990) DISCLOSES: ALPSSECURITIES, INC., HAD AN ORDER TO SHOW CAUSE AND SUMMARYSUSPENSION ISSUED ON JANUARY 30, 1990, FOR FAILURE TO HAVE ANAGENT REGISTERED, VIOLATION OF SEC. 11-412(a)(2) OF THE ACT.ALPS SECURITIES, INC. DID NOT REGISTER AN AGENT OR REQUEST AHEARING. FINAL ORDER OF REVOCATION ISSUE MARCH 14, 1990. ALPSSECURITIES, INC. WAS FINED $1,000.00 FOR ADMINISTRATIVE COSTSAND THE BROKER-DEALER REGISTRATION WAS REINSTATED APRIL 34,1990. DOCKET/CASE NO. BD-90-0076, DATED APRIL 30, 1990, MARYLANDDIVISION OF SECURITIES.

Sanctions Ordered: Monetary/Fine $1,000.00Revocation/Expulsion/Denial

Decision







Initiated By: STATE OF MARYLAND, DIVISION OF SECURITIES


Revocation


NONE.


Docket/Case Number: N/A



Allegations: FAILURE OF APPLICANT TO REGISTER AT LEAST ONE AGENT WITH THEDIVISION IN ASSOCIATION WITH APPLICANT'S REGISTRATION AS ABROKER-DEALER WITH THE DIVISION.



Resolution:

Other Sanctions Ordered: NONE

Sanction Details: APPLICANT'S BROKER-DEALER REGISTRATION WAS REVOED INMARYLAND EFFECTIVE MARCH 14, 1990. REGISTRATION WAS REINSTATEDEFFECTIVE MAY 1,1990.`

Firm Statement APPLICANT SUBMITTED AN UNDERTAKING TO THE DIVISION CERTIFYINGTHAT IT WOULD COMPLY WITH PROCEDURES ENACTED TO PREVENTFUTURE VIOLATIONS OF THE MARYLAND SECURITIES ACT. INREPONSE,THE DIVISION OF SECURITIES ISSUED AN ORDER OF REINSTATEMENT OFAPPLICANT'S BROKER-DEALER REGISTRAION.

Sanctions Ordered: Revocation/Expulsion/Denial

Settled






End of Report

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